This chapter presents the scope of this report, i.e. the standard, the jurisdictions and the recommendations covered and analysed in the report. It also details the procedure followed to arrive at the conclusions presented in the individual reports of the monitored jurisdictions. Specifically, it explains the meaning and implications of different statuses determined for the recommendations and clarifies the situations where new recommendations are issued to monitored jurisdictions.
Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025
Abstract
The methodology for enhanced monitoring has been adhered to for the 2025 enhanced monitoring exercise.1
Standard covered
This report covers the progress made by monitored jurisdictions in implementing the standard on transparency and exchange of information on request (the EOIR standard), as observed in the framework of the first round of enhanced monitoring.2
Jurisdictions covered
This annual monitoring report presents a first set of individual jurisdiction reports for the jurisdictions under cycle 1 of the first round of enhanced monitoring.
The enhanced monitoring process is performed in successive rounds and, within each round, jurisdictions are spread in two groups, called two cycles. Cycle 1 includes 87 jurisdictions and cycle 2 includes 88 jurisdictions.3 Not all jurisdictions are monitored in a given round, for the following reasons:
First, jurisdictions that have not yet completed their peer review under the second round of EOIR peer reviews (i.e. their baseline review) are not subject to the enhanced monitoring process until such time as when their peer review report has been adopted by the Global Forum and published.4
Second, jurisdictions whose in-depth review is either ongoing or is scheduled for launch during the year of enhanced monitoring are exempted until such time their review reports have been adopted by the Global Forum and published.5
As a result, the enhanced monitoring exercise invited the submission of self-assessments from 82 of the 87 jurisdictions assigned to cycle 1. All 82 jurisdictions have provided their self-assessments. Of these, one jurisdiction has undergone only a Phase 1 review and will be provided with feedback by the Secretariat, but a report will not be published. Thus, 81 individual jurisdiction reports will be published for jurisdictions in cycle 1. This monitoring report covers the first 25 of these reports. Similar reports will be issued in 2026 to cover the remaining 56 jurisdictions in cycle 1, and in 2027 covering the jurisdictions in cycle 2.6
Recommendations covered
There are three types of recommendations. Recommendations issued in peer review reports, which can either be “in-box” recommendations or “in-text” recommendations, and recommendations issued during the previous follow-up process, which are treated the same as in-box recommendations in a peer review report.
In-box recommendations
In-box recommendations reflect deficiencies that are material issues that have had an impact or that are likely to have an impact on the proper implementation of the EOIR standard in the jurisdiction. They require the jurisdiction to correct the deficiencies identified in its legal and regulatory framework and/or in respect to the implementation of the standard in practice. In-box recommendations are displayed in boxes in the peer review reports and are compiled at the end of the executive summary of the report.
The 82 monitored jurisdictions in cycle 1 account for a total of 662 in-box recommendations. This first annual monitoring report, covering 25 jurisdictions, analyses the 125 in-box recommendations issued to these jurisdictions in their EOIR peer review reports.
Number of recommendations analysed and presented by nature of gap identified – Legal and regulatory framework or Implementation in practice
Source: The Global Forum Secretariat
In-text recommendations
In-text recommendations reflect issues identified in a jurisdiction that have not had or that are unlikely, in the circumstances of the jurisdiction at the time of the review, to have more than a negligible impact on EOIR in practice. An in-text recommendation is given in such circumstances as there is a concern that the circumstances might change, and the relevance of the issue identified may increase. These in-text recommendations are not contained in the recommendation boxes in the EOIR peer review reports but appear in a dedicated Annex.
Exceptionally, for the first round of enhanced monitoring, the actions reported by monitored jurisdictions to address in-text recommendations have been examined only when a jurisdiction has requested to be permitted to stop reporting on all its recommendations, as it considered that it has addressed all the recommendations.
Recommendations issued during the previous annual follow-up process or under the current enhanced monitoring process
The enhanced monitoring process examines recommendations issued to jurisdictions during the earlier annual follow-up process and under the current enhanced monitoring process in the same manner as in-box recommendations issued in a peer review. For this first set of 25 reports, no jurisdiction had received a recommendation under the earlier annual follow-up process. On the other hand, some of the 25 jurisdictions have been issued with new recommendations under the enhanced monitoring process, and the progress made to address such new recommendations will be examined in due course.
The agreed methodology is adhered to for the enhanced monitoring exercise. The process includes an invitation for peer input on the monitored jurisdictions, submissions of self-assessments by the monitored jurisdictions (along with detailed reports where the jurisdiction considers it has addressed all its recommendations), analysis of the self-assessments and peer input by the Global Forum Secretariat and the assessment panel (where required under the methodology), preparation of draft individual jurisdiction reports, approval of the reports by the PRMG, and subsequent adoption of the reports by the Global Forum Plenary.
The process followed is described below, including some details with respect to the process in 2025.
Step 1. Peer input
Peer input on the 82 monitored jurisdictions in cycle 1 was called for between 1 November 2024 and 31 January 2025, on EOI requests sent or received in the calendar years 2023-2024. The peer input questionnaire covers all relevant aspects of the EOIR relationship between the reporting peer and the monitored jurisdiction. In particular, it seeks supporting statistics on the timeliness of responses to requests made and feedback on the overall quality of the responses. Similarly, peers were invited to provide input on the quality of the requests received from the monitored jurisdictions.
The peer input received was shared with the monitored jurisdictions to provide them with the opportunity to consult with their peers, where necessary, and to provide responses in their self-assessments.
Step 2. Self-assessment by monitored jurisdictions
Monitored jurisdictions were invited in mid-February 2025 to submit their self-assessments by 31 March 2025. In their self-assessments, jurisdictions were mainly required to:
update the reported actions taken to address all recommendations issued in their latest peer review report, and in the context of earlier enhanced follow-up processes, if any
provide statistical details on their EOIR experience, on incoming and outgoing requests, during the monitoring period and on the timeliness of their responses to incoming requests
provide details of any new developments that have a bearing on the implementation of the EOIR standard in the jurisdiction (for instance, any new legislation, administrative practices or procedures, judicial decisions or tax cooperation agreements) and
provide their responses on any matter identified in the peer input.
Detailed reports from certain jurisdictions: A jurisdiction that considers that it has addressed all its in-box recommendations may make a request, supported by a detailed report, to be permitted to stop reporting on its recommendations in the future rounds of enhanced monitoring. Out of the 25 jurisdictions covered in this report, 2 made such a request.7 In addition, one jurisdiction that had already been permitted to stop reporting on its in-box recommendations prior to the commencement of the enhanced monitoring process, requested for a similar consideration of its in-text recommendations by providing a detailed report on them.8
Step 3. Preparatory analysis
The Secretariat carried out a comprehensive analysis of the submissions made in the jurisdictions’ self-assessments and the peer input. Where peer input raised a matter that required a response from the jurisdiction, the Secretariat consulted both the monitored jurisdiction and the peer concerned to facilitate a bilateral resolution. All matters that suggested issues with a broader implication for the standard (i.e. beyond the bilateral relationship) were brought to the attention of the assessment panel for its views.
Step 4. Assessment Panel
In October 2024, the PRMG put in place an 11-member assessment panel comprising experts in the area of EOIR to assist the PRMG on various specific matters. These include:
Situations of concern, for the assessment panel to provide its views on the type of action that should be taken in respect of a jurisdiction where there are indications of a persistent lack of progress (e.g. downgrading a rating or launching an in-depth review), backsliding (e.g. issuance of a recommendation for immediate remedial action with annual updates, or launching an in-depth review), or an issue with broader implications on compliance with the standard arising from matters raised in the peer input (e.g. issuance of a new recommendation or launching an in-depth review).
Requests by a jurisdiction to stop reporting, for the assessment panel to provide its views where a jurisdiction submits a detailed report indicating that it has addressed all recommendations and wishes to seek the PRMG’s approval to stop reporting on them in future rounds of enhanced monitoring.
For the 25 individual jurisdiction reports, the assessment panel was engaged for 6 reports –3 situations of concern and 3 requests to stop reporting.
Step 5. PRMG decisions
Statuses determined and actions required
Based on the analysis prepared by the Secretariat on the recommendations and, where applicable, reflecting the views of the assessment panel, the PRMG decided on a status for every recommendation in each individual jurisdiction report.
The following different statuses have been indicated in respect of the recommendations:
For addressed recommendations there are two possible statuses – For the recommendations that appear to have been addressed, the statuses reflect the level of confidence that can be reasonably expressed in the context of a desk-based analysis under the enhanced monitoring process. The assigned status also conveys whether any further updated information on the recommendation is expected from the jurisdiction for future consideration by the assessment panel or the PRMG. Two statuses therefore appear in the individual monitoring reports:
Considered addressed in the context of the monitoring process (subject to a peer review) – In such cases no further reporting on the recommendation is required by the jurisdiction in the framework of the enhanced monitoring process. This status applies where the assessment panel has examined a jurisdiction’s report prepared on the basis of the jurisdiction’s detailed submissions (seeking to stop reporting on all recommendations, in accordance with paragraphs 50 to 53 of the methodology for enhanced monitoring) and has expressed satisfaction with the reported actions on a recommendation, and this view is subsequently confirmed by the PRMG. This status remains until the jurisdiction is subject to an in-depth review.
Considered provisionally addressed in the context of the monitoring process subject to detailed validation – In such cases the PRMG is confident that the recommendation can be accepted as addressed in the context of the monitoring process and no immediate next steps are expected from the jurisdiction in its next self-assessment. However, updated information is expected whenever the jurisdiction a) submits a detailed report to stop reporting on all the recommendations, or b) requests an in-depth review. Hence, the jurisdiction should continue to maintain up-to-date information in respect of a recommendation that is assigned this status, in anticipation of the need to submit updated information on the recommendation in the future.
In this report, where a collective reference to these “addressed” recommendations is made, they have been referred to as “considered (provisionally) addressed”. In general, a jurisdiction is not expected to report any further actions in relation to a recommendation assigned either of these two statuses. However, where a recommendation pertaining to the timeliness of the exchange of information is assigned either of these two statuses, the jurisdiction must continue to provide updated timeliness statistics for the corresponding monitoring period in its next self-assessment.
In the process of being addressed – In such cases substantive actions have been taken to address the recommendation, but these have not been completed, or further action is still required, to fully address the recommendation or specific parts of it (for example, draft legislation has been submitted to parliament for approval, or steps have been taken to put in place an EOI team). If a period of more than three years has elapsed since the issuance of the recommendation and the recommendation continues to be “in the process of being addressed” without further material progress, the PRMG systematically asks the jurisdictions concerned to provide a schedule for completion of the actions taken to address the recommendations in full and to provide an annual update on the progress made in implementing the recommendation.
Has not been addressed – In such cases no action has been undertaken to address the recommendation, or only preliminary steps have been taken. If a period of more than three years has elapsed since the issuance of the recommendation and the recommendation continues to be “has not been addressed”, the PRMG systematically asks the jurisdictions concerned to provide a schedule for completion of actions to address the recommendation and to provide a related annual update.
No longer sufficiently material – In limited situations, the PRMG, informed by a recommendation by the assessment panel as applicable, may consider that, although a jurisdiction has not shown progress in addressing a recommendation, the recommendation is not sufficiently relevant, substantive or material to warrant further action. In such cases, the recommendation may be determined as “no longer sufficiently material” and the jurisdiction need not report further on it (either until it submits a detailed report to stop reporting on all the recommendations, or requests an in-depth review, depending on the circumstances).
Permission to stop reporting on recommendations
As noted at Step 2 above (“Detailed reports from certain jurisdictions”), jurisdictions seeking to stop reporting on their recommendations submitted detailed reports on the actions they took to address the recommendations. Based on these detailed reports, the Secretariat prepared individual jurisdiction reports which were examined by the assessment panel. The views of the assessment panel on the status of each recommendation were considered by the PRMG. Where all in-box and in-text recommendations were found to be sufficiently addressed, the jurisdiction was permitted to stop reporting on them. Where some in-text recommendations were not yet considered to be fully addressed, the PRMG invited such jurisdictions to continue to provide updates on them in their next self-assessments.
Issuance of new recommendations
New recommendations were issued to jurisdictions under the enhanced monitoring process in two scenarios.
First, new recommendations were made where a new issue was identified. The PRMG was informed by the views of the assessment panel, which examined the identified issue, considered the views and submissions of the peers providing the input (if any), the response of the monitored jurisdiction and the analysis on the matter prepared by the Global Forum Secretariat. Where a new recommendation was added on account of backsliding, the jurisdiction was asked to submit an update on the actions taken to address it by 31 March 2026.
Second, new recommendations were issued where a jurisdiction addressed a recommendation issued to it in its EOIR peer review report and where, as a result, a new issue was identified. The PRMG recognised the progress made by the jurisdiction and accepted the original recommendation as addressed but considered it appropriate to issue a new recommendation to clearly communicate what further action is expected from the jurisdiction.
New recommendations focused on the effective implementation of legal and regulatory amendments brought into force to address the initial recommendation: This is where the jurisdiction had not (yet) been able to demonstrate that the implementation of the new provisions meets the standard (i.e. that the implementation of the legislative or regulatory change is effective in practice). In such cases, the original recommendation was accepted as addressed and a new recommendation, focused on the practical implementation, was issued in its place.
New recommendations focused on pending or related aspects relevant to achieve satisfactory compliance with the standard: Where a jurisdiction had taken measures to correct a deficiency identified in a recommendation, but the measures taken may have introduced some other deficiencies or gaps that affect full compliance with the standard, a new recommendation has been issued. The new recommendation indicates the newly identified deficiency, along with a new underlying factor.
The jurisdictions concerned are required to report on these new recommendations in their next self-assessment.
Change of ratings
Jurisdictions that have made progress to address their recommendations might want to have this progress reflected in improved ratings. For this, they must request an in-depth review. The enhanced monitoring process does not, as a general rule, provide for change of ratings. This is because a change of ratings requires a similar level of comfort as was available under the review process through which they were issued. An in-depth peer review is more extensive and detailed and normally includes an onsite visit, which offers a more holistic examination of the situation in a jurisdiction compared to the desk-based enhanced monitoring process. Thus, while the enhanced monitoring process recognises the progress made by jurisdictions, it does not provide for upgrades to ratings.
While changes to rating(s) are generally not possible under the enhanced monitoring process, there is one situation where it is possible that a jurisdiction’s rating(s) is downgraded. Where the PRMG considers that there is a persistent lack of progress by a jurisdiction to address its recommendation(s), its rating(s) may be downgraded. Such a decision is not automatic and depends on a detailed consideration of the situation. Furthermore, if the impact of the persistent lack of progress cannot be ascertained solely through a desk-based monitoring, the PRMG can decide on the launch of an in-depth review. Both decisions are actions of last resort for severe deterioration of compliance and threat to the level playing field.
Such a downgrade of ratings or launch of an in-depth review have not been applied to any of the 25 jurisdictions covered in this annual monitoring report.
Step 6. Approval and adoption
This report, including all of the jurisdiction reports, as approved by the PRMG, was submitted to all the Global Forum members for adoption. It was adopted by the Global Forum Plenary on 24 November 2025.
← 1. The Methodology for Enhanced Monitoring is available in Part II of the OECD (2025), Handbook for Second Round Peer Reviews and New Monitoring Processes on Transparency and Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD, Paris, https://www.oecd.org/tax/transparency/documents/handbook-for-second-round-peer-reviews-and-new-monitoring-processes-on-transparency-and-exchange-of-information-on-request.pdf.
← 2. The other standards overseen by the Global Forum are not yet covered by the enhanced monitoring process.
← 3. This includes 172 members of the Global Forum and 3 relevant non-members.
← 4. One jurisdiction in cycle 1 –Sierra Leone – is a new member of the Global Forum and has not yet been reviewed. While it is allocated to cycle 1, like other new members, it will undergo enhanced monitoring only upon completion of their EOIR peer reviews. The review of some jurisdictions is split into two phases: Phase 1 on the legal and regulatory framework, and Phase 2 up to four years later, on the implementation of the standard and legal framework in practice. For the first round of enhanced monitoring, the Global Forum agreed jurisdictions that have only undergone a Phase 1 review were invited to submit their self-assessments indicating the steps undertaken to address the recommendations, in order to receive feedback from the Secretariat on the reported actions. A report was not prepared for publication. For cycle 1, this applies to one jurisdiction – Ukraine. Further, exceptional exemptions may be decided on by the PRMG. Russia has been exceptionally excluded from the process.
← 5. Three jurisdictions – Antigua and Barbuda, Seychelles and Vanuatu were not covered in this round for this reason.
← 6. As a transitional measure for implementing the enhanced monitoring process, the Global Forum agreed to have the first round of enhanced monitoring over a three-year period (2025-2027). Cycle 1 will be completed over 2025-2026, while cycle 2 is planned to be completed in 2027. The Global Forum will monitor these timelines and may revisit them as needed.
← 7. See the reports of Bahrain and Luxembourg.
← 8. See the report of Liechtenstein.